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Flexo Sustainable : Year-End 2013
ardous waste regulations or because it exhibits the character- istic of ignitability. Types of wipes include: • Shop Towel • Rag • Pad • Swab And they can be made from a variety of materials, such as: • Wood Pulp • Fabric • Cotton • Polyester Solvent contaminated wipes do not include wipes contami- nated with hazardous waste other than solvents, or that exhib- it any of the characteristics of toxicity, corrosivity or reactivity due to contaminants, other than solvents. CONTAINERS To be excluded, solvent contaminated wipes must be man- aged in closed containers that are labeled “Excluded Solvent Contaminated Wipes.” These must contain free liquids when sent for off site cleaning or disposal. Managing wipes in non leaking, closed containers ensures that the solvents are unlikely to be released to the environment. Closed and labeled containers serve to minimize solvent emissions, prevent spills, avoid cross contamination (of collected wipes) and reduce any risk of fire by spontaneous combustion or external ignition sources. NO FREE LIQUIDS Solvent contaminated wipes shall not contain free liquids at the point of being sent for cleaning or disposal. Removal of free liquids prior to being sent off site significantly reduces the potential for solvents to be leaked or spilled into the environ- ment. In order to meet the performance standard, generators may choose from a range of methods to remove solvent from the wipe: • Centrifuging • Mechanical Wringing • Screen Bottom Straining Drums • Microwave Technology • Vacuum Extraction The EPA eliminated the proposed “dry ” standard for dis- posable wipes, which would have required each to contain less than five grams of solvent prior to being disposed in a non hazardous waste landfill. Instead, disposable wipes must contain no free liquids, which is the same standard used for those going to combustors, laundries and dry cleaners. The majority of states use the Paint Filter Liquids Test (Method 9095B) for determining whether solvent contami- nated wipes contain no free liquids. The test is simple and inexpensive to perform and typically produces clear results. It includes placing a predetermined number of contaminat- ed wipes in a paint filter. A 100 mL. or 100 g. representative sample is required for the test, but larger samples in multi- ples of 100 mL. or 100 g.— 400 mL. or 200 g., for example— may be used. However, when larger samples are used, they must be divided into 100 mL. or 100 g. portions and each must be tested separately. If the sample is measured volumetrically, then it should lack major air spaces or voids. If any portion contains free liquids, the entire sample is considered to have free liquids. The testing for “free” liquids is straightforward. Place solvent contaminated wipes, taken from the lowest point of the collection container, in a suspended paint filter. If, after five minutes, no solvent drips from the filter, the contaminated wipes have passed the “no free liquids” test. This does not mean generators must conduct the test for every solvent contaminated wipe. Rather, generators must ensure that if the Paint Filter Liquids Test was performed, the solvent contaminated wipe would pass. Free liquid solvent removed from the wipes must be man- aged as hazardous waste. Free liquids removed from the solvent contaminated wipes and/or from the container hold- ing the wipes must be managed according to the applicable hazardous waste regulations found in 40 CFR 260-273 and may be recycled to further reduce a facility ’s environmental footprint. GENERATOR STATUS Under federal rule, reusable wipes are not solid wastes and therefore not hazardous wastes. As a result, solvent contaminated wipes managed under conditional exclusion do not count toward a generator’s hazardous waste regulatory status. However, free liquid solvent removed from solvent contami- nated wipes or container holding the wipes must be managed according to the applicable hazardous waste regulations found in 40 CFR 260-273, which would include counting to- ward determining monthly generator status. 10 Sustainable FLEXO YEAR END 2013 www.flexomag.com
Earth Day 2014